Rwanda

Rwanda is a landlocked country in Eastern Africa that borders the Democratic Republic of Congo (DRC), Tanzania, Uganda, and Burundi. There are approximately 154,542 FDPs (refugees, asylum-seekers, and others of concern to UNHCR) in Rwanda at the end of 2020.39

127,382

As of August 2021, Rwanda has around 127,382 refugees and asylum-seekers, out of which the majority are from DRC and Burundi.40

51%

The gender distribution in refugee camps is 51 percent female and 49 percent male with the highest proportion of FDPs being under 18 years of age.

There are six camps hosting refugees in Rwanda, namely, Gihembe, Kigeme, Kiziba, Mugombwa, Nyabiheke, and Mahama, as well as an Emergency Transit Mechanism center to receive evacuees from Libya. Around nine percent of the refugee population live in an urban setting.

Rwanda is a signatory to the 1951 Convention on the status of refugees and the 1967 Protocol relating to the status of refugees. These conventions laid the foundation of national laws governing the “right to asylum” and “determination of refugee status”. The right to seek asylum is enshrined in the Constitution of Rwanda under Article 28 of Chapter IV.

In 2018, Rwanda signed the Comprehensive Refugee Response Framework (CRRF) reiterating its commitment to promoting inclusion, identification, and integration with national social protection systems, including the health and education of refugees.41

Rwanda has recently undertaken strong institutional measures regarding FDPs. As per its pledge at the High-Level Segment on Statelessness in 2019, Rwanda has established a National Statelessness Taskforce and drafted a National Action Plan (2020-2024) to Eradicate Statelessness in Rwanda, which operationalized the pledges made, including on identification of stateless persons and persons with undetermined nationality, legal amendments to provide for nationality pathways for stateless persons, and improve birth registration for refugees.42

The Ministry of Finance and Economic Planning heads the implementation of the Rwanda National Financial Inclusion Strategy (2019-2024).43 The strategy aims to provide financial services to the entire population and targeted interventions for the inclusion of vulnerable groups such as refugees, however it does not provide any explicit targets towards that end. Notably, financial exclusion in Rwanda has dropped from 11 percent in 2016 to seven percent in 2020 (equivalent to five million adults). The significant drop can be attributed to the increase in the number of adults served by formal financial institutions. Financial institutions have increased their reach by expanding the services offered and developing new banking channels. There has also been an increase in services offered by nonbank financial institutions such as SACCOs and mobile money service providers. The Rwanda Finscope Report 2020 indicated an increase in the use of mobile money accounts from 2.3 million users in 2016 to 4.4 million users in 2020.44

DIGITAL ID LANDSCAPE FOR FDPs

Since 2007, the government has been maintaining a computerized National Population Register (NPR), which includes both foreigners and refugees.45 In 2015, the government of Rwanda launched a digital ID that seeks to transform the identity ecosystem of Rwanda. The purpose of the digital ID is to increase electronic transactions.46

39 UNHCR. 2021. Global Trends in Forced Displacement – 2020. Geneva.

Available at: https://www.unhcr.org/60b638e37/unhcr-globaltrends-2020 40 UNHCR. 2021. UNHCR Rwanda – Operational update, August 2021.

Geneva. Available at: https://reporting.unhcr.org/sites/default/files/

Rwanda%20Operational%20Update-August%202021.pdf 41 UNHCR. 2020. Rwanda Country Refugee Response Plan. Rwanda.

Available at : https://reporting.unhcr.org/sites/default/files/

Rwanda%20Country%20Refugee%20Response%20Plan%202020-2021%20 -%20March%202020.pdf 42 UNHCR. 2013. Global Action Plan to End Statelessness: 2014-2024.

Geneva. Available at: https://www.unhcr.org/54621bf49.html 43 Access to Finance Rwanda. 2020. FinScope 2020 Report. Kigali City.

Available at: https://www.bnr.rw/fileadmin/user_upload/2020_Rwanda_

Finscope.pdf 44 Access to Finance Rwanda. 2020. FinScope 2020 Report. Kigali City.

Available at: https://www.bnr.rw/fileadmin/user_upload/2020_Rwanda_

Finscope.pdf 45 Rwanda’s historical identity records were destroyed during the conflict. (Atick, Joseph J. 2016. The Identity Ecosystem of Rwanda: A Case

Study of a Performant ID System in an African Development Context.

ID4Africa. Kigali. Available at: https://www.id4africa.com/2016/files/

ID4Africa2016_The_Identity_Ecosystem_of_Rwanda_eBooklet.pdf ) 46 Atick, Joseph J. 2016. The Identity Ecosystem of Rwanda: A Case

Study of a Performant ID System in an African Development Context.

ID4Africa. Kigali. Available at: https://www.id4africa.com/2016/files/

ID4Africa2016_The_Identity_Ecosystem_of_Rwanda_eBooklet.pdf

The National Identification Agency (NIDA) has been issuing refugee ID cards to refugees above the age of 16. The Agency issues different national identification cards to residents, foreigners, and refugees. The first digit of the identification number printed on the card can be 1, 2, or 3 depending on whether the card is a national ID, a foreigner’s ID, or a refugee ID. UNHCR and the government of Rwanda also jointly issue proof of registration identification to refugees, which is a paper document ID in A4 format.47 The proof of registration document allows refugees to travel across Rwanda but it cannot be used for employment. Only Equity Bank provides bank accounts to refugees on the basis of proof of registration to allow access to cash assistance given by UNHCR and WFP. The proof of registration document is accepted only after the confirmation from UNHCR.48

The government of Rwanda and UNHCR are currently conducting biometric enrolment for refugee IDs with an estimated coverage of about 75 percent as of early 2021.49

In March 2018, the Ministry of Emergency Management or MINEMA (previously the Ministry of Disaster Management and Refugees or MIDIMAR), NIDA, and UNHCR jointly launched a verification exercise of refugees and asylum-seekers to update information as well as verify their physical presence in the country through biometric data.50 The exercise aimed to give refugees greater access to identity documents, which would facilitate their ability to access government services, jobs and business opportunities outside the camps, formal financial services, and machine-readable travel documents.

47 UNHCR. Working in Rwanda. Available at: https://help.unhcr.org/ rwanda/services/work/ 48 UNHCR. 2019. Displaced and Disconnected – Country Reports. Geneva.

Available at: https://www.unhcr.org/innovation/wp-content/ uploads/2019/04/Displaced-Disconnected-WEB.pdf 49 Key informant interview 50 UNHCR. February 2018. The Government of Rwanda and the UN

Refugee Agency launch a joint verification exercise of refugees and asylum seekers residing in Rwanda. Available at: https://www.unhcr. org/rw/12906-government-rwanda-un-refugee-agency-launch-jointverification-exercise-refugees-asylum-seekers-residing-rwanda.html 51 UNHCR. October 2018. The Government of Rwanda and the UN Refugee

Agency launch the issuance of Machine Readable Refugee Travel

Documents. UNHCR – Rwanda. Available at: https://www.unhcr.org/ rw/13674-the-government-of-rwanda-and-the-un-refugee-agencylaunch-the-issuance-of-machine-readable-refugee-travel-documents. html

The provision for issuance of machine-readable travel documents to refugees was introduced in 2018.51 These documents contain biometric data and security features allowing international travel for refugees in line with requirements specified by the Directorate General of Immigration and Emigration,52 enabling them to seek better business opportunities. The requirements for the issue of machine-readable travel documents involves filling in an application letter addressed to the Director-General of Immigration and Emigration, a recommendation letter issued at the administrative cell or camp manager level, a copy of proof of registration, a copy of a valid refugee card and presentation of the original (if any), one recent passport photo in color, and a payment slip of RWF20,000 (USD19.50) paid to Irembo.53 Irembo is an e-government platform that aims to digitize over 100 public services to allow easier access to Rwandan nationals and foreigners. The services available under Irembo can be accessed through multiple modes, including online, USSD, and agents. The machine-readable travel documents are available to both adults above 16 years and minors below the age of 16 years.

As a result of the verification exercise, by December 2019, 148,848 refugees53 had been registered individually and 1,107 were registered at a group level. In addition, 6,422 birth certificates had been issued to children born to refugees.55

UNHCR is responsible for capturing refugees' and asylum-seekers’ biometric details including fingerprints, irises, and photographs. NIDA is responsible for the registration of eligible refugees for the refugee ID using fingerprints and photographs. Once an individual (refugee, asylum-seeker or those who fall into other categories) is registered with UNHCR, they are issued with a proof of registration document. Subsequently, if eligible, refugees who are 16 years and above are enrolled for refugee IDs.

The digitization of government services through Irembo may also facilitate easier access to registration for FDPs.

DATA PROTECTION AND PRIVACY

In May 2017, UNHCR and the government of Rwanda created a data-sharing mechanism to exchange and access data on refugees. Through MINEMA and NIDA, the government is responsible for safeguarding data relating to refugees. Rwanda has also enacted a data protection law restricting the unauthorized use of personal data of data subjects. The law is not specific to the handling of data of refugees. Rwanda has also signed and ratified the African Union Convention on Cyber Security and Personal Data Protection, which covers natural persons which is supposed to cover refugees.56

NIDA and UNHCR are responsible for collection of data on refugees. UNHCR uses the guidelines on registration57 and identity management which are part of the policy on persons of concern to UNHCR.58 The policy was put in place to prevent unauthorized loss or disclosure of personal information of FDPs. The UNHCR signed a Memorandum of Understanding (MOU) with their implementation partners, such as the WFP,59 on the data that can be shared. The MoU includes the data transfer agreement between UNHCR and the implementing partner, outlining the terms and conditions for use of personal data including the data components to be shared, the intended use, mode of transfer, and security measures.60

51 UNHCR. October 2018. The Government of Rwanda and the UN Refugee

Agency launch the issuance of Machine Readable Refugee Travel

Documents. UNHCR – Rwanda. Available at: https://www.unhcr.org/ rw/13674-the-government-of-rwanda-and-the-un-refugee-agencylaunch-the-issuance-of-machine-readable-refugee-travel-documents. html 52 Directorate General of Immigration and Emigration, Government of

Rwanda. Refugee Travel Document. Rwanda Directorate General of

Immigration and Emigration – Our Services. Accessed 19 February 2022

Available at: https://www.migration.gov.rw/our-services/refugee/ 53 According to immigration website Directorate General of Immigration and Emigration, Government of Rwanda. Refugee Travel Document.

Rwanda Directorate General of Immigration and Emigration – Our

Services. Accessed 19 February 2022 Available at: https://www. migration.gov.rw/our-services/refugee/) 54 This includes refugees that have willingly repatriated to their home countries. 55 UNHCR, et.al. 2020. RWANDA Country Refugee Response

Plan (CRP) 2020-2021.Available at: https://reporting.unhcr. org/sites/default/files/Rwanda%20Country%20Refugee%20

Response%20Plan%202020-2021%20-%20March%202020.pdf#_ ga=2.140193523.1569461358.1645191318-1611624227.164519131856

African Union. 2014. African Union Convention on Cyber Security and

Personal Data Protection. (27 June 2014). Addis Ababa. Available at: https://au.int/sites/default/files/treaties/29560-treaty-0048_-_ african_union_convention_on_cyber_security_and_personal_data_ protection_e.pdf 57 UNHCR. Guidance on Registration and Identity Management. Accessed on 19 February 2022. Available at: https://www.unhcr.org/registrationguidance/ 58 UNHCR. Policy on the Protection of Personal Data of Persons of

Concern to UNHCR. Available at: https://cms.emergency.unhcr.org/ documents/11982/52542/Data+Protection+Policy/06bc03cf-e969-4329a52b-161ae1eb42d7 59 UNHCR and the World Food Programme. May 2017. Addendum on

Cash Assistance to Refugees to the January 2011 Memorandum of

Understanding Between the United Nations High Commissioner for

Refugees (UNHCR) and the World Food Programme (WFP). Available at: https://www.unhcr.org/596e13717.pdf 60 UNHCR, The World Food Programme, UNICEF. October 2020. Data Sharing

Agreement among the Office of the United Nations High Commissioner for Refugees, the World Food Programme and the United Nations

Children’s Fund in the context of programmes involving transfers of cash assistance to beneficiaries in humanitarian situations. Available at: https://www.unhcr.org/602e24a94.pdf and UNHCR and the World Food

Programme. May 2017. Addendum on Cash Assistance to Refugees to the January 2011 Memorandum of Understanding Between the United

Nations High Commissioner for Refugees (UNHCR) and the World Food

Programme (WFP). Available at: https://www.unhcr.org/596e13717.pdf

ACCESS TO FORMAL FINANCIAL SERVICES

Rwanda has made impressive progress in advancing the financial inclusion of FDPs through various governmentled initiatives and close partnerships with development and humanitarian agencies. FDPs have access to bank accounts offered by financial institutions such as Equity Bank. The eligible refugee households in some camps who receive the UNHCR and WFP cash aid are given bank accounts linked with a Mastercard debit card which is issued to the head of the household.61 Some refugees may have also access to a cross-border digital wallet named “Leaf”62 that allows them to do remittance transactions through either a smartphone or a feature phone using USSD.

FDPs in Rwanda also have access to mobile money accounts provided by mobile network operators such as MTN.

There is a visible divide in access to SIM cards and mobile money usage between urban and rural refugees. Urban refugees, who mainly reside in Kigali and the Huye district, can purchase SIM cards at various mobile money centers using UNHCR proof of registration. However, refugees living in rural camps (constituting about 92 percent),63 face difficulties in accessing SIM cards since rural agents cannot register nonRwandan nationals.

Some agents in rural areas collect copies of proof of registration and deliver them to the nearest mobile registration centers for activation of SIM cards. This often takes time, making the process cumbersome for rural refugees.

The access to credit to FDPs seems to be limited to informal channels through shopkeepers in the camp. However, MNOs such as Airtel and Tigo are also trying to partner with banks to offer microcredit and loans to refugees.

According to a study by BFA Global published in March 2018,64 there is a strong case for FSPs to provide formal financial services targeted to refugees in Rwanda. The report’s estimates are based on Maastricht Graduate School of Governance (MGSG) data of 2016. They say that over 90 percent of refugee households report income from various sources above RWF25,000 per month which translates to USD300 annually. The average annual household income in Rwanda is about USD 40065 (2015) and GDP per capita according to the World Bank is USD820 (2019).66 The income source includes salaried jobs (nine percent), remittances (four percent), those receiving cash transfers and holding salaried jobs (10 percent), those receiving cash transfers plus wages from odd jobs (27 percent), those receiving cash transfers plus remittances (four percent), and those receiving cash transfers only (35 percent).

Kindly refer to Appendix A to understand the availability of formal financial services to FDPs with respect to the length of their displacement.

KYC ECOSYSTEM

Rwanda is part of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG),67 a FATFStyle Regional Body (FSRB). The country amended its AML/CFT law68 in 2020, paving a way for the full criminalization of money laundering and terrorist financing (ML/TF) activities and confiscation of illicit proceeds.

The Rwandan Financial Intelligence Centre requires regulated entities to identify their customers as residents or non-residents before establishing business relationships. The minimum requirements for the opening of a personal bank account for an individual include: original and copy of passport, laissez-passer

61 According to FSD Africa 2019 Report: Refugees and their money, The

Mastercard debit card is issued to the head of the household. (BFA

Global. 2018. Refugees and Their Money: The Business Case for Providing

Financial Services to Refugees. FSD Africa. Available at: https:// bfaglobal.com/wp-content/uploads/2020/01/Refugees-and-Their-

Money_-Assessing-the-Business-Case-for-Providing-Financial-Services-to-

Refugees.pdf) 62 Leaf Global Fintech. https://leafglobalfintech.com/ 63 UNHCR. 2019. Fact Sheet - Rwanda as of 15 October 2019. Geneva.

Available at: https://reporting.unhcr.org/sites/default/files/UNHCR%20

Rwanda%20Fact%20Sheet%20-%2015OCT19.pdf ) 64 BFA Global. 2018. Refugees and Their Money: The Business Case for Providing Financial Services to Refugees. Available at: https:// bfaglobal.com/wp-content/uploads/2020/01/Refugees-and-Their-

Money_-Assessing-the-Business-Case-for-Providing-Financial-Services-to-

Refugees.pdf 65 BFA Global. 2018. Refugees and Their Money: The Business Case for Providing Financial Services to Refugees. Available at: https:// bfaglobal.com/wp-content/uploads/2020/01/Refugees-and-Their-

Money_-Assessing-the-Business-Case-for-Providing-Financial-Services-to-

Refugees.pdf 66 World Bank. GDP per capita (Current US$) – Rwanda. Accessed on 19

February 2022. Available at: https://data.worldbank.org/indicator/

NY.GDP.PCAP.CD?locations=RW 67 IMF. September 2014. Mutual Evaluation Report: Anti-Money Laundering and Combating the Financing of Terrorism – Republic of Rwanda. Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG). Available at: https://www.esaamlg.org/index.php/all_news/readmore_news/84 68 Mwai, Collins. 29 July 2020. Why Rwanda amended anti-money laundering law. Available at: https://www.newtimes.co.rw/news/ rwanda-amend-anti-money-laundering-law

COMPARISON OF THE UNHCR AND GOVERNMENT-ISSUED REFUGEE ID WITH THE DESIGN PARAMETERS OF A GOOD ID69

PARAMETERS

PRIVACY

This parameter adjudicates data collection, sharing, and usage. UNHCR has signed an MoU with the government of Rwanda on data sharing and access to refugees’ data in 2017. UNHCR follows guidelines on registration and identity management.70 NIDA is in charge of the National Population Register. UNHCR maintains the most updated refugee data but shares refugee basic data with NIDA through MINEMA to produce refugee IDs and help with the issuance of other Civil Registration and Vital Statistics (CRVS) documents such birth certificates.

INCLUSION

USER VALUE

USER AGENCY

SECURITY

UNHCR- AND MINEMA-ISSUED PROOF OF REGISTRATION (POR) GOVERNMENT-ISSUED REFUGEE ID

Rwanda has established a data protection law that restricts the unauthorized use of personal data by data processors. This offers protection and privacy of data subjects. The law, however, does not provide specific conditions for handling refugee data. Rwanda has also ratified the African Union Convention on Cyber Security and Personal Data Protection.

All FDPs are eligible for PoR.

The UNCHR proof of registration allows refugees to move out of the camp and to open mobile money accounts in urban areas only. A few of the financial institutions like Equity Bank have been accepting the proof of registration document for opening of bank accounts to allow refugees to access cash assistance from UNHCR and WFP. The refugee ID is of great value to FDPs. It allows refugees to be gainfully employed, start businesses, open bank accounts and obtain machine-readable travel documents for international travel.

There are no mentions of any FDP communities being excluded from national IDs.

Registration with UNCHR is voluntary. Refugees, just like foreigners have to report to the government’s Directorate General of Immigration and Emigration for registration. Those who are above 16 years are eligible for a refugee ID.

NIDA and UNHCR follow a rigorous data protection policy to ensure that refugee data is secure. UNHCR has a dedicated data protection policy (Policy on the Protection of Personal Data of Persons of Concern to UNHCR).71 It also adheres to UNHCR’s guidance for registration and identity management.72

69 Good ID is a term used by the Omidyar Network to characterize the good practices in digital ID systems. (Omidyar Network. 16 May 2019. Omidyar

Network Unpacks Good ID: An Update to Our Point of View on Digital Identity. Available at: https://omidyar.com/omidyar-network-unpacks-good-idupdate-our-point-view-digital-identity/ ) 70 UNHCR. Guidance on Registration and Identity Management. Accessed on 19 February 2022. Available at: https://www.unhcr.org/registration-guidance/ 71 UNHCR. 2015. Data Protection Policy – Policy on the Protection of Personal Data of Persons of Concern to UNHCR. Geneva. Available at: https://cms. emergency.unhcr.org/documents/11982/52542/Data+Protection+Policy/06bc03cf-e969-4329-a52b-161ae1eb42d7 72 UNHCR. Guidance on Registration and Identity Management. Accessed on 19 February 2022. Available at: https://www.unhcr.org/registration-guidance/

or ID where applicable, a high-quality passport size photo in color, an account opening application form, a letter from the employer confirming an employment contract, address, employment visa, copy of a Taxpayer Identification Number (TIN), and acceptance of terms and conditions.73 There are two major mobile network operators in Rwanda namely MTN and Airtel-Tigo. According to MTN,74 the minimum requirements for opening a mobile money account for foreigners in Rwanda are a valid passport, a laissez-passer, or a letter from the employer confirming employment, or a valid visa.

These KYC requirements, however, have limited the ability of FSPs to serve FDPs. Most FDPs may find it difficult to produce all the requirements such as the TIN number, letter from employer confirming employment, contact address, and employment visa. Following the verification exercise in 2018, some refugees have refugee ID cards that they can use to open bank accounts, but some still face difficulties in accessing financial services using these cards75 because of the lack of verifiable addresses and TIN numbers. Equity Bank is one of the few financial institutions that accepts UNHCR refugee IDs for the opening of bank accounts.

On the other hand, the financial inclusion of FDPs has also been accelerated through institutional reforms and innovations. NIDA has spearheaded the innovations in digital identification in Rwanda as part of its mandate of modernizing the national population registration.

Computerization and integration of the various registries have enabled easier KYC processes as FSPs can leverage real-time identity verification and validation.76

STEPS TAKEN TO ADVANCE FINANCIAL AND ECONOMIC INCLUSION OF FDPs

Rwanda has endorsed the United Nations Development Assistance Plan (2018-2023), which is aligned with the National Strategy for Transformation with a focus on three pillars:77 economic transformation, social transformation, and transformational governance.

The UN Development Assistance Plan (2018-2023) focuses on the inclusion of refugees in national systems instead of developing parallel systems meant for refugees.78 The inclusion of refugees in the national systems began in August 2018 with the joint verification exercise of UNHCR and the government of Rwanda. This improved the issuance and delivery of refugee IDs and birth certificates.

The effective multi-agency response, comprising government actors such as NIDA, private sector organizations like Mastercard, financial sector actors like Equity Bank, and humanitarian agencies including UNHCR, UNCDF and WFP, has significantly contributed to the financial inclusion of refugees through the enhancement of demand for financial products and services. This has been done through the shift from primarily food assistance to cash-based interventions (in line with the UNHCR’s priorities) which has accorded FDPs greater choice. Access to market-linked livelihood interventions such as allowing refugees to participate in economic activities and access to labor markets. This is partly contributing to the creation of a “demandpull” for financial services among FDPs due to improved economic empowerment and purchasing power.

Several interventions have been undertaken jointly by government and development agencies to provide better access to financial services to FDPs. Examples include UNCDF-led program expanding financial access, digital and financial literacy for refugees’ program (REFAD)79 that has been implemented to increase access to financial services through capacity building of local FSPs, and strategic partnerships to design and roll out innovative financial services and products.

73 Rwanda National Police. 2015. Directive No 001/FIU/2015 of 30/12/2015 of the Financial Investigation Unit Relating to the Identification of

Customers, Suspicious Transactions Reporting and Record Keeping

Requirements for Reporting Entities. Available at: https://www.police. gov.rw/uploads/tx_download/doc06762320160121085053.compressed. pdf 74 Mobile Telecommunications Network (MTN). Mobile Money Service:

Terms and Conditions. Accessed 19 February 2022. Available at: https://www.mtn.co.rw/wp-content/uploads/2019/11/MOMO-TERMS-

CONDITIONS.pdf 75 UNHCR. 2019. Displaced and Disconnected – Country Reports. Geneva.

UNHCR. Available at: https://www.unhcr.org/innovation/wp-content/ uploads/2019/04/Displaced-Disconnected-WEB.pdf 76 Mukesha, Josephine. 2019. Reforming Identity Management Practices in Rwanda. Report presented at 5th Annual Meeting of the ID4Africa

Movement. 18 June 2019. Available at: https://www.id4africa. com/2019_event/presentations/PS1/5-Josephine-Mukesha-NIDA-

Rwanda.pdf ) 77 Office of the UN Resident Coordinator, United Nations Rwanda. 2018.

UNDAP II - the United Nations Development Assistance Plan 2018-2023.

Kigali. Available at: https://rwanda.un.org/en/1236-undap-ii-unitednations-development-assistance-plan-2018-2023 78 UNHCR et al. 2020. RWANDA Country Refugee Response Plan (CRP) 2020-2021. Available at: https://reporting.unhcr.org/sites/default/files/

Rwanda%20Country%20Refugee%20Response%20Plan%202020-2021%20 -%20March%202020.pdf#_ga=2.140193523.1569461358.16451913181611624227.1645191318 79 Ogba, Uloma. 2019. Rwanda: Expanding Financial Access & Digital And

Financial Literacy For Refugees Programme (REFAD)”. Unlocking Public and Private Finance for the Poor (UNCDF) Blog. Available at: https:// www.uncdf.org/article/4681/uncdf-rwanda---expanding-financialaccess-digital-and-financial-literacy-for-refugees-programme-refad